Vendor Guru Q&A - Compliance

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Latest Compliance - Reg. BB Topics

How to Report Revolving Lines of Credit (Extended)

10/01/2017

I am trying to obtain a good definition and/or guidance on how to report Revolving Lines of Credit that have been extended and not renewed for a particular year. Example – A customer has a revolving line of credit for $250,000 that originally was executed in November 2014 and is up for renewal in November 2015, however the borrower has asked for a 3-month extension which the bank granted, the amount and conditions are unchanged. For 2015 reporting, can we/should we be reporting/treating the $250,000 as a renewal/extension that took place in 2015? Or not report it as it was an extension and not a renewal according to the CRA quidelines?

CRA Reporting of Gross Revenue (Reg BB)

08/13/2017

The CRA regulation states, "generally, an institution is to rely on the revenues that it considered in making its credit decision." It also states, "The regulation does not require institutions to request or consider revenue information when making a loan; however, if institutions do gather this information from their borrowers, the agencies expect them to collect and rely upon the borrowers' gross revenue for purposes of CRA." Does one of these trump the other? We use personal income for the credit decision and rarely use gross revenues of the business. Our auditors think the "credit decision" amounts outweigh using what we have in the file. If we only used the credit decision amounts, we wouldn't have many loans to report.

Documentation to Prove Community Development Loan

05/25/2015

What documentation would you suggest to prove a community development loan with the purpose of revitalization/stabilization in a moderate- income area? We are financing the purchase and construction of a mixed use development with upper income housing, retail and commercial space. The housing units have been completed but our loan will finance the finish out of the retail/commercial space. Development has TIF credits that our borrower will receive.

Protected Funds Apply to Child Support Levies?

04/14/2019

I recently did an e-train webinar, regarding California Levies/Subpoenas as my credit union is located in California and Oregon. In this e-training the instructor told us that protected funds do not apply to child support levies. I have been to many seminars regarding levies and subpoenas and I have never been told this. I was taught of course that IRS levies do not apply to protected funds, but never child support. Does this rule only apply to California or to all states?

Reg E Unauthorized Transaction w/PIN Issue

04/14/2019

REG E, if a consumer has given his or her PIN to a friend, the friend later steals the card [and uses it without authority], are we required to give them their money back under Reg E?

Family Trust-Individuals Use Separate SSANs?

04/14/2019

John and Cindy both have individual accounts and just created a family trust which has no tax number. Can they use their separate SSANs for the account without adding the other person as joint owner?

Violation if Make ATM Unavailable for Week?

04/14/2019

If we deactivate the card reader access to ATM area and make ATM unavailable for about a week, will it cause any violation on to regulation? Our bank’s ATM is inside a building. Anyone who wants to access the ATM machine needs to get in the first door with access via a card. There is another door before you get to the bank’s lobby. There is a small area between the first door and second door. Recently we found a homeless person who gets in that area around midnight and sleeps there. Even worse thing is he urinates during the night and leaves unpleasant smell before leaving early in the morning. We are hoping the person will find a new place to stay if we temporarily shut it down.

State Requirements: Lender-Placed Insurance

04/07/2019

I'm looking for a resource that can provide the state-specific requirements for lender-placed insurance notifications - this would be above/beyond the CFPB model forms.

Latest Compliance - Reg. BB Topics

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